ML072960625

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Application for Technical Specification Improvement to Eliminate Requirements for Hydrogen Recombiners and Hydrogen/Oxygen Monitors Using the Consolidated Line Item Improvement Process
ML072960625
Person / Time
Site: Nine Mile Point Constellation icon.png
Issue date: 10/22/2007
From: Polson K
Constellation Energy Group
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML072960625 (28)


Text

<:eith J. Polson Vice President-Nine Mile Point Constellation Energy"

~ Nine MilePoint NuclearStation U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 P.O. Box 63 Lycoming, New York 13093 315.349.5200 315.349.1321 Fax October 22, 2007

SUBJECT:

Nine Mile Point Nuclear Station Unit No.2; Docket No. 50-410 License No. NPP-69 Application for Technical Specification Improvement to Eliminate Requirements for Hydrogen Recombiners and Hydrogen/Oxygen Monitors Using the Consolidated Line Item Improvement Process Pursuant to 10 CPR 50.90, Nine Mile Point Nuclear Station, LLC (NMPNS) hereby requests an amendment to the Nine Mile Point Unit 2 (NMP2) Renewed Facility Operating License NPF-69. The proposed changes to the Technical Specifications (TSs) contained herein would revise TS Section 3.6.3.1, "Primary Containment Hydrogen Recombiners," and TS Section 3.3.3.1, "Post Accident Monitoring (PAM) Instrumentation."

The proposed changes will delete the TS requirements related to the hydrogen recombiners and hydrogen/oxygen monitors. The proposed TS changes support implementation of the revisions to 10 CFR 50.44, "Combustible Gas Control for Nuclear Power Reactors," that became effective on October 16, 2003. The changes are consistent with Revision 1 of NRC-approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-447, "Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors." The availability of this TS improvement was announced in the Federal Registeron September 25, 2003 as part of the consolidated line item improvement process (CLIIP).

Consistent with the revised 10 CPR 50.44, this proposed amendment will also relocate the requirements of the Renewed Facility Operating License (POL) paragraph 2.C.(11a), which requires establishing containment hydrogen monitoring within 90 minutes of initiating emergency core cooling following a loss of coolant accident, from the FOL to the NMP2 Updated Safety Analysis Report (USAR).

Attachment (1) provides a description of the proposed changes, the requested confirmation of applicability, and plant-specific verifications and commitments.

Attachment (2) provides the existing FOL and TS pages marked-up to show the proposed changes. Associated TS Bases changes are shown in

Document Control Desk October 22, 2007 Page 2 Attachment (3).

The TS Bases changes are provided for information only and will be processed in accordance with the NMP2 TS 5.5.10, "Technical Specifications (TS) Bases Control Program."

NMPNS requests approval ofthis request by April 2008 with implementation within 60 days of approval ofthe amendment.

Pursuant to 10 CFR 50.91(b)(1), NMPNS has provided a copy of this license amendment request, with attachments, to the appropriate state representative.

Should you have any questions regarding the information in this submittal, please contact T. F. Syrell, Licensing Director, at (315) 349-5219.

Very truly yours, STATE OF NEW YORK TO WIT:

COUNTY OF OSWEGO I, Keith J. Polson, being duly sworn, state that I am Vice President-Nine Mile Point, and that I am duly authorized to execute and file this request on behalfofNine Mile Point Nuclear Station, LLC. To the best ofmy knowledge and belief, the statements contained in this document are true and correct. To the extent that these statements are not based on my personal knowledge, they are based upon information provided by other Nine Mile Point employees and/or consultants.

Such information has been reviewed in accordance with company practice and I believe it to be reliable.

Subscribed and sworn before me, a Notary Public in and for the State ofNew York and County of Oswego, this J..A.. day of ~

, 2007.

WITNESS my Hand and Notarial Seal:

Notary Public My Commission Expires:

Date SANDRA A. OSWALD Notary Public, Stale of ~!ew York No. 010S60322,6 Qualified in Qswego C.?~}'_o'i.

Commission Expires

--!./~C>~=-..-...._~

Document Control Desk October 22, 2007 Page 3 KJP/GBI Attachments:

(1)

(2)

(3)

Description and Assessment Proposed Facility Operating License and Technical Specification Changes (Marked Up Pages)

Changes to Technical Specifications Bases (Marked Up Pages) cc:

S. J. Collins, NRC Region 1 Administrator M. J. David, NRC Project Manager E. C. Knutson, Senior NRC Resident Inspector J. P. Spath, NYSERDA

ATTACHMENT (1)

DESCRIPTION AND ASSESSMENT TABLE OF CONTENTS

1. INTRODUCTION
2. DESCRIPTION OF PROPOSED AMENDMENT
3. BACKGROUND
4. REGULATORY REQUIREMENTS AND GUIDANCE
5. TECHNICAL ANALYSIS
6. REGULATORY ANALYSIS
7. NO SIGNIFICANT HAZARDS CONSIDERATION
8. ENVIRONMENTAL EVALUATION
9. PRECEDENT
10. REFERENCES Nine Mile Point Nuclear Station, LLC October 22, 2007

ATTACHMENT (1)

DESCRIPTION AND ASSESSMENT

1.0 INTRODUCTION

The proposed License amendment deletes Nine Mile Point Unit 2 (NMP2) Technical Specification (TS) 3.6.3.1, "Primary Containment Hydrogen Recombiners," and references to the hydrogen and oxygen monitors in TS 3.3.3.1, "Post Accident Monitoring (PAM) Instrumentation." The proposed TS changes support implementation of the revisions to 10 CFR 50.44, "Combustible Gas Control for Nuclear Power Reactors," that became effective on October 16, 2003.

The changes are consistent with Revision 1 of NRC-approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-447, "Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors." The availability of this TS improvement was announced in the Federal Register on September 25,2003 (Reference 1) as part of the consolidated line item improvement process (CLIIP).

Consistent with the revised 10 CFR 50.44, this proposed amendment also relocates from the Renewed Facility Operating License (FOL) to the NMP2 Updated Safety Analysis Report (FSAR), FOL paragraph 2.C.(11a), "Additional Condition 3," which requires establishing containment hydrogen monitoring within 90 minutes of initiating emergency core cooling following a loss of coolant accident. This is a plant-specific change that is in addition to the TS changes identified in TSTF-447.

2.0 DESCRIPTION

OF PROPOSED AMENDMENT Consistent with the NRC-approved Revision 1 ofTSTF-447, the proposed TS changes include:

Table 3.3.3.1-1 TS 3.6.3.1 Table of Contents Item 9, Drywell H2 Concentration Analyzer Item 10, Drywell O2 Concentration Analyzer Item 11 renumbered Primary Containment Hydrogen Recombiners Remove 3.6.3.1, Primary Containment Hydrogen Recombiners on Page iii Deleted Deleted Revised Deleted Deleted In support ofthe deletion ofthe hydrogen and oxygen monitors, the following TS changes are also being made. The changes are considered minor variations and do not otherwise affect the proposed amendment.

Surveillance SR 3.3.3.1.2 Surveillance SR 3.3.3.1.3 Channel Calibration Frequency for Drywell Hydrogen and Oxygen Concentration Analyzers (Functions 9 and 10)

Remove References to Functions 9 and 10 and SR renumbered from 3.3.3.1.3 to 3.3.3.1.2 Deleted Revised The implementation of the proposed amendment also results in changes to various TS Bases sections. provides marked up Bases pages that are being submitted for information only. The TS Bases changes will be submitted with a future update in accordance with TS 5.5.10, "Technical Specifications (TS) Bases Control Program."

Page 1 of5

ATTACHMENT (1)

DESCRIPTION AND ASSESSMENT The following additional plant-specific change to the FOL is included in this license amendment request:

FOL paragraph 2.C.(11a)

3.0 BACKGROUND

"Additional Condition 3" Deleted Hydrogen and Oxygen Monitors and the Hydrogen Recombiners The background for the application associated with the hydrogen and oxygen monitors in TS 3.3.3.1, and the hydrogen recombiners in TS 3.6.3.1 is adequately addressed by the NRC Notice of Availability published on September 25, 2003 (68 FR 55416), TSTF-447, the documentation associated with the 10 CFR 50.44 rulemaking, and other related documents.

Renewed Facility Operating License Paragraph 2.C.Ola)

FOL paragraph 2.C.(lIa), "Additional Condition 3" states that "The operating licensee shall be capable of establishing containment hydrogen monitoring within 90 minutes of initiating emergency core cooling (safety injection) following a loss of coolant accident."

This license condition was added to the NMP2 Operating License (TS Amendment No.102, approved February 25, 2002), to amend the licensing basis time requirement for establishing containment hydrogen monitoring, after initiation of safety injection, from 30 minutes to 90 minutes.

4.0 REGULATORY REQUIREMENTS AND GUIDANCE Hydrogen and Oxygen Monitors and the Hydrogen Recombiners The applicable regulatory requirements and guidance associated with this application are adequately addressed by the NRC Notice of Availability published on September 25, 2003 (68 FR 55416), TSTF-447, the documentation associated with the 10 CFR 50.44 rulemaking, and other related documents.

Renewed Facility Operating License paragraph 2.C.01a)

The NMP2 Updated Safety Analysis Report (USAR), Table 1.9, commits NMP2 to comply with the acceptance criteria ofNUREG-0800, Standard Review Plan (SRP), Section 6.2.5 (Reference 2), stating:

"The containment hydrogen monitor shall meet the requirements of Item ILF.I of NUREG-0737 and NUREG-0718, and the Appendix of Regulatory Guide 1.97." (Reference 4)

Section II.F.I, Attachment 6, ofNUREG-0737 states, "a continuous indication of hydrogen concentration in the containment atmosphere shall be provided in the control room. If an indication is not available at all times, continuous indication and recording shall be functional within 90 minutes after initiation of safety injection." Thus, the current commitment found in both the USAR and the FOL form the current licensing basis.

On September 16, 2003, the NRC revised 10 CFR 50.44 based on risk considerations resulting in the requirements related to hydrogen monitoring being removed from the TSs.

The 90 minute initiation requirement remains part of the NMP2 licensing basis requirements and will be retained in the NMP2 USAR.

Page 2 of5

ATTACHMENT (1)

DESCRIPTION AND ASSESSMENT 5.

TECHNICAL ANALYSIS Hydrogen and Oxygen Monitors and the Hydrogen Recombiners NMPNS has reviewed the safety evaluation (SE) published on September 25,2003 (68 FR 55416) as part ofthe CLIIP Notice of Availability. This verification included a review of the NRC staff's SE, as well as the information provided to support TSTF-447. NMPNS has concluded that the justifications presented in the TSTF proposal and the Safety Evaluation prepared by the NRC staff are applicable to NMP2 and justify this amendment for the incorporation ofthe changes to the NMP2 TS.

Renewed Facility Operating License paragraph 2.C.01a),

Revised 10 CFR 50.44 requires that the hydrogen monitors be functional but are no longer considered a required instrument to mitigate a design basis accident (DBA). Therefore, the components: (1) are not required to meet the definition of a safety related component as defined in 10 CFR 50.2; and (2) no longer meet the definition of Category 1 in Regulatory Guide 1.97.

The proposed change to delete paragraph 2.C.(11a) from the FOL, and retain the current licensing basis hydrogen monitoring requirement in the NMP2 USAR is consistent with the proposed change to remove the hydrogen monitors from the TS (and relocate to the Technical Requirements Manual, see Section 6.1).

Changes to the facility or procedures as described in the USAR are controlled by the provisions of 10 CFR50.59.

6.0 REGULATORY ANALYSIS

6.1 Verification and Commitments Hydrogen and Oxygen Monitors and the Hydrogen Recombiners As discussed in the model SE published in the Federal Register on September 25, 2003 (68 FR 55416) for the TS 3.3.3.1 and TS 3.6.3.1 improvements, NMPNS is making the following verifications and regulatory commitments:

a.

NMPNS has verified that a hydrogen monitoring system capable of diagnosing beyond design-basis accidents is installed at NMP2.

REGULATORY COMMITMENT DUE DATE NMPNS IS making a

regulatory commitment to This commitment will be maintain a hydrogen monitoring system capable of implemented within 60 diagnosing beyond design-basis accidents.

The days from the date ofthe hydrogen monitors will be included in the NMP2 approval ofthe proposed Technical Requirements Manual (TRM).

amendment.

Page 3 of5

ATTACHMENT (1)

DESCRIPTION AND ASSESSMENT b.

NMP2 has an inerted containment.

NMPNS has verified that an oxygen monitoring system capable of verifying the status of the inerted containment is installed at NMP2.

REGULATORY COMMITMENT DUE DATE NMPNS IS making a regulatory commitment to This commitment will be maintain an oxygen monitoring system capable of implemented within 60 verifying the status of the inerted containment. The days from the date ofthe oxygen monitors will be included in the NMP2 approval ofthe proposed Technical Requirements Manual (TRM).

amendment.

7.0 NO SIGNIFICANT HAZARDS CONSIDERATION NMPNS has reviewed the proposed no significant. hazards consideration determination published on September 25, 2003 (68 FR 55416) as part of the CLIIP.

NMPNS has concluded that the proposed determination presented in the notice is applicable to NMP2 and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

8.0 ENVIRONMENTAL EVALUATION NMPNS has reviewed the environmental evaluation included in the model safety evaluation published on September 25,2003 (68 FR 55416) as part ofthe CLIIP. NMPNS has concluded that the staff's findings presented in that evaluation are applicable to NMP2 and the evaluation is hereby incorporated by reference for this application.

9.0 PRECEDENT This application is being made in accordance with the CLIIP.

NMPNS is not proposing any deviations from the applicable Technical Specifications changes described in TSTF-447 or the NRC staff's model safety evaluation published on September 25, 2003 (68 FR 55416). However, the deletion of the hydrogen and oxygen monitors resulted in two minor variations to the changes described in TSTF-447, specifically, numbering and formatting changes to Technical Specifications SR 3.3.3.1.2 and SR 3.3.3.1.3, which were otherwise unaffected by this proposed amendment.

An additional change to delete Renewed Facility Operating License paragraph 2.C.(lla),

"Additional Condition 3" is also proposed.

This change is appropriate since all of the requirements related to hydrogen monitoring are being removed from the Technical Specifications, and the 90 minute hydrogen monitoring initiation time currently specified in the Renewed Facility Operating License is also contained in the NMP2 USAR.

Page 4 of5

ATTACHMENT (1)

DESCRIPTION AND ASSESSMENT

10.0 REFERENCES

1.

Federal Register Notice: Notice of Availability ofModel Application Concerning Technical' Specification Improvement To Eliminate Hydrogen Recombiner Requirement, and Relax the Hydrogen and Oxygen Monitor Requirements for Light Water Reactors Using the Consolidated Line Item Improvement Process, published September 25,2003, (68 FR 55416).

Page 5 of5

ATTACHMENT (2l PROPOSED FACILITY OPERATING LICENSE AND TECHNICAL SPECIFICATION CHANGES (MARKED UP PAGES)

Operating License Page TS Table ofContents Page iii TS Page 3.3.3.1-3 TS Page 3.3.3.1-4 TS Page 3.6.3.1-1 TS Page 3.6.3.1-2 Nine Mile Point Nuclear Station, LLC October 22, 2007

-6.

(10)

Additional Condition 1 The operating licensee isauthonzed by Amendment No. 91 torelocate certain TechnicaJ Specification requirements previously included in Appendix Atolicensee-controlled documents, as described in Table R, Relocated Specifications and Removal ofDetails Matrix, attached to the NRC Staff's safety evaluation dated February 15,2000, enclosed with the amendment. Implementation ofAmendment No. 91 shall include the relocation ofthese requirements tothe appropdate documents, which shall be completed no later than December 31,2000.. The relocations to the Updated Safety Analysis Report shall be reflected inupdates completed in accordance with 10 CFR 50.71(e).

(11)

Additional Condition 2 The schedule for performing Surveillance Requirements (SRs) that are new orrevised in Amendment No. 91 shall be as follows:

For SRs that are new in this amendment,the first performance isdue at the end ofthe first surveillance interval that begins on the data of implementation ofthis amendment.

For SRs that existed prior tothisamendment whose intervals of performance are being reduced, the first reduced surveillance interval begins upon completion of the first surveillance performed after implementation of this amendment.

For SRs that existed prior tothis amendment that have modified acceptance criteria, the first performance isdue atthe end ofthe first surveillance interval that began on the datethe surveillance was last performed prior to the implementation of this amendment.

For SRs that existed priorto this amendment whose intervalsof performance are being extended, the first extended surveillance interval begins upon completion ofthe last surveillance performed prior tothe implementationof thisamendment.

(11 a)

Additional Condition 3 (DELETED)

The Of;)oFating lisensee shall be capable of establishing containment hydFOgen monit9fing within 90 minutes ofinitiating emergency core cooling (safety injeGtien) follelJ,ling aloss ofcoolant accident.

(12)

On the closing date(s) ofthe transfer ofthe NMPC, RG&E, CHGEC, and NYSEG interests in NMP-2 toit, Nine Mile Point Nuclear Station, LLC shall: (1) obtain from the transferors then transferring their interests all of their accumulated decommissioning trust funds for NMp-2, and (2)

Renewed License No. NPF 69 Amendment

TABLE OF CONTENTS 3.6 3.6.3.1 3.6.3.2 3.6.4.1 3.6.4.2 3.6.4.3 3.7 3.7.1 3.7.2 3.7.3 3.7.4 3.7.5 3.7.6 3.8 3.8.1 3.8.2 3.8.3 3.8.4 3.8.5 3.8.6 3.8.7 3.8.8 3.8.9 3.9 3.9.1 3.9.2 3.9.3 3.9.4 3.9.5 3.9.6 3.9.7 3.9.8 3.9.9 3.10 3.10.1 3.10.2 3.10.3 CONTAINMENT SYSTEMS (continued)

Primary Containment Hydrogen Reoembiners DELETED 3.6.3.1-1 Primary Containment Oxygen Concentration 3.6.3.2-1 Secondary Containment 3.6.4.1 -1 Secondary Containment Isolation Valves (SCIVs) 3.6.4.2-1 Standby Gas Treatment (SGT) System 3.6.4.3-1 PLANT SYSTEMS Service Water (SW) System and Ultimate Heat Sink (UHS) 3.7.1-1 Control Room Envelope Filtration (CREF) System 3.7.2-1 Control Room Envelope Air Conditioning (AC)

System 3.7.3-1 Main Condenser Offgas 3.7.4-1 Main Turbine Bypass System 3.7.5-1 Spent Fuel Storage Pool Water Level 3.7.6-1 ELECTRICAL POWER SYSTEMS AC Sources - Operating 3.8.1-1 AC Sources - Shutdown 3.8.2-1 Diesel Fuel Oil, Lube Oil, and Starting Air 3.8.3-1 DC Sources - Operating 3.8.4-1 DC Sources - Shutdown 3.8.5-1 Battery Cell Parameters 3.8.6-1 Inverters - Operating 3.8.7-1 Distribution Systems - Operating 3.8.8-1 Distribution Systems - Shutdown 3.8.9-1 REFUELING OPERATIONS Refueling Equipment Interlocks 3.9.1-1 Refuel Position One-Rod-Out Interloek..

3.9.2-1 Control Rod Position 3.9.3-1 Control Rod Position Indication 3.9.4-1 Control Rod OPERABILITY - Refueling 3.9.5-1 Reactor Pressure Vessel (RPV) Water Level - Irradiated Fuel.

3.9.6-1 Reactor Pressure Vessel (RPV) Water Level-New Fuel or Control Rods 3.9.7-1 Residual Heat Removal (RHR) - High Water Level 3.9.8-1 Residual Heat Removal (RHR) - Low Water LeveL 3.9.9-1 SPECIAL OPERATIONS System Leakage and Hydrostatic Testing Operation 3.10.1-1 Reactor Mode Switch Interlock Testing 3.10.2-1 Single Control Rod Withdrawal - Hot Shutdown 3.10.3-1 (continued)

NMP2 iii Amendment 9-=1-,

SURVEILLANCE PAM Instrumentation 3.3.3.1 FREQUENCY SR 3.3.3.1.2 2

SR 3.3.3.1.J NMP2 Perform CHP.t'JNEL CALIBRATION for 92 days Functions 9 and 10.

Perform CHANNEL CALIBRATION. for Functions 24 months other than Fl::lnctions 9 and 10.

3.3.3.1-3 Amendment 94,

PAM Instrumentation 3.3.3.1 Table 3.3.3.1-1 (page 1 of 1)

Post Accident Monitoring Instrumentation FUNCTION 1.

Reactor Vessel Pressure 2.

Reactor Vessel Water Level

a. Fuel Zone Range b.

Wide Range 3.

Suppression Pool Water Level REQUIRED CHANNELS 2

2 2

CONDlTiONS REFERENCED FROM REQUIRED ACTION D.1 E

E E

a. Narrow Range b.

Wide Range 4.

Drywell Pressure

a. Narrow Range b.

Wide Range 5.

Drywell Radiation (High Range) 6.

Drywell Air Temperature 7.

Suppression Chamber Pressure 8.

PCIV Position

-10.

Drywell 02~ratiofl.Anal)lC9f 9

+;..

Suppression Pool Water Temperature 2

E 2

E 2

E 2

E 2

F 2

E 2

E 2 per penetration E

flow path(a)(b)

~

e;

~

E 2(c)

E (a)

Not required for isolation valves whose associated penetration flow path is isolated by at least one closed and de-activated automatic valve. dosed manual valve. blind flange. or check valVe with flow through the valve secured.

(b)

Only one position indication channel is required for penetration flow paths with only one installed control room indication channel.

(e)

Monitoring each suppression pool quadrant.

NMP2 3.3.3.1-4 Amendment 94-,

Primary Containment Hydrogen Recombiners 3.6.3.1 3.6 CONTAINMENT SYSTEMS 3.6.3.1 Primary Containment Hydrogen Recombiners (DELETED)

LCO 3.6.3.1 Two primary containment hydrogen recombiners shall be OPERABLE.

APPLlC,A:; ILlTY: MODES 1 and 2.

ACTIONS COND ITIO A.

One primary containment hydrogen recombiner inoperable.

B.

Two primary containment hydrogen recombiners inoperable.

B.1 AND B.2 REQUIRED ACTION Restore primary containment hydr recombiner to OPERABL tatus.

Restore one primary containment hydrogen recombiner to OPERABLE status.

30 days 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter 7

s NMP2 3.6.3.1-1 Amendment 9-1-, +00.

24 months

~__,_...._.,,,~~":':';<jt*:Mjfi't~,.,,,_~.._,I~ ':.'t'.~,~

I FREQUENCY Be in MODE 3.

REQUIRED ACTION C.1 Perform a resistance to ground test for each heater phase.

Pe rm a system functional test for ch

. unary containment hydrogen recombi

- CONDITION Primary Containment Hydrogen Recombiners 3.6.3.

SR 3.6.3.1.1 C.

Required Aati~ and associated Co letion Time nat met.

ACTIONS (continued

- - ----.--..------ - - - -t---- --- - - - - -+- + - - - - -

(Delete Entire Page)

NMP2

,~-

ATTACHMENT (3)

CHANGES TO TECHNICAL SPECIFICATION BASES (MARKED UP PAGES)

The current version of the following Technical Specification Bases pages have been marked-up by hand to reflect the proposed changes. These Bases pages are provided for information only and do not require NRC approval.

TS Bases Table ofContent, Page B ii TS Bases Page B 3.3.3.1-7 TS Bases Page B 3.3.3.1-12 TS Bases Page B 3.6.3.1-1 TS Bases Page B 3.6.3.1-2 TS Bases Page B 3.6.3.1-3 TS Bases Page B 3.6.3.1-4 TS Bases Page B 3.6.3.1-5 TS Bases Page B 3.6.3.1-6 TS Bases Page B 3.6.3.2-1 TS Bases Page B 3.6.3.2-2 Nine Mile Point Nuclear Station, LLC October 22, 2007

TA8LE OF CONTENTS 8 3.3 83.3.7.1 8.3.3.7.2 83.3.8.1 8 3.3.8.2 B 3.3.8.3 83.4 83.4.1 83.4.2 83.4.3 83.4.4 B3.4.5 83.4.6 83.4.7 83.4.8 83.4.9 83.4.10 83.4.11 B 3.4.12 8 3.5 83.5.1 8 3.5.2 8 3.5.3 8 3.6 83.6.1.1 83.6.1.2 B 3.6.1.3 83.6.1.4 83.6.1.5 83.6.1.6 83.6.1.7 83.6.2.1 8 3.6.2.2 8 3.6.2.3 83.6.2.4 B 3.6.3.1 8 3.6.3.2 NMP2 INSTRUMENTATION (continued)

Control Room Envelope Filtration (CREF) System Instrumentation 8 3.3.7.1-1 Mechanical Vacuum Pump Isolation Instrumentation B 3.3.7.2-1 Loss of Power (LOP) Instrumentation 8 3.3.8.1-1 Reactor Protection System (RPS) Electric Power Monitoring -

Logic 8 3.3.8.2-1 Reactor Protection System (RPS) Electric Power Monitoring-Scram Solenoids 8 3.3.8.3-1 REACTOR COOLANT SYSTEM (RCS)

Recirculation Loops Operating 8 3.4.1-1 Flow Control Valves (FCVs) 8 3.4.2-1 Jet Pumps 8 3.4.3-1 Safety/ReliefValves (SIRVs) 8 3.4.4-1 RCS Operational LEAKAGE 8 3.4.5-1 RCS Pressure Isolation Valve (PIV) Leakage 8 3.4.6-1 RCS Leakage Detection Instrumentation B3.4.7-1 RCS Specific Activity 8 3.4.8-1 Residual Heat Removal (RHR) Shutdown Cooling System -

Hot Shutdown 8 3.4.9-1 Residual Heat Removal (RHR) Shutdown Cooling System-Cold Shutdown 8 3.4.10-1 RCS Pressure and Temperature (PIT) Limits 8 3.4.11-1 Reactor Steam Dome Pressure 8 3.4.12-1 EMERGENCY CORE COOLING SYSTEMS (ECCS) AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM ECCS -

Operating 8 3.5.1-1 ECCS -

Shutdown B 3.5.2-1 RCIC System B 3.5.3-1 CONTAINMENT SYSTEMS Primary Containment 83.6.1.1-1 Primary Containment Air Locks 8 3.6.1.2-1 Primary Containment Isolation Valves (PC IVs) '"

8 3.6.1.3-1 Drywell and Suppression Chamber Pressure B 3.6.1.4-1 Drywell Air Temperature 8 3.6.1.5-1 Residual Heat Removal (RHR) Drywell Spray 8 3.6.1.6-1 Suppression Chamber-to-Drywell Vacuum 8reakers 8 3.6.1.7-1 Suppression Pool Average Temperature B 3.6.2.1-1 Suppression Pool Water Level.

83.6.2.2-1 Residual Heat Removal (RHR) Suppression Pool Cooling B 3.6.2.3-1 Residual Heat Removal (RHR) Suppression Pool Spray 8 3.6.2.4-1 Primar/ Containment HyaFogen Reoombinors (DELETED)

B 3.6.3.1-1 Primary Containment Oxygen Concentration B 3.6.3.2-1

.................................................................(continued)

Bii Revision (),

BASES LCO (continued)

PAM Instrumentation 8 3.3.3.1 ents that represent a t inverifying the REMOVE Hydrogen and oxygen concentrations a Independent analyzers and upon rna ac

'onofthe analyzers, Are continuously monitored in ntrol room.

function is monitored by one indicator (f one recorder. The ana are capable ofoperating from 12. to 45 psig. The range ofthe drywe from 0% to30%

ile the range ofthe oxygen analyzer isfrom 0% to 10° he recorders are the primary indication used by the ope rduring an accident. Therefore, thePAM Specification deals specifica s portion ofthe instrument channeL 9

44. Suppression Pool Water Temperature Suppression pool water temperature isaType Aand Category I variable provided to Detect acondition that could potentially lead tocontainment breach, and toverify The effectiveness ofECCS actions taken toprevent containment breach. The suppression pool water temperature instrumentationallows operators to detect trends insuppression pool watertemperature insufficient time totake action to prevent steam quenching vibrations inthe suppression pool. Eight temperature sensors are arranged infour groups oftwo independent and redundant channels, located such that there isone group ofsensors ineach quadrant ofthe suppression pool. The range ofthe suppression pool water temperature channels isfrom 50°F to 250°F.

Thus, four groups ofsensors are sufficient tomonitorthe Bulk average temperature of The suppression pool. The outputs for the PAM sensors are monitored on an indicator and two recorders in the control room. One group ofsensors provdes input only to an indicator while the other group ofsensors provides input toboth an indicator and two recorders, but only the two recorders are required forthis group. Both the indicator and the two recorders must be OPERABLE to furnish two channels ofPAM indication for each quadrant ofthe suppression pool. Aselector switch is

{continued}

NMP2 83.3.3.1-7 Revision 0, 7 (A102),

BASES SURVEILLANCE REQUIREMENTS REFERENCES PAM Instrumentation B 3.3.3.1 SR 3.3.3.1.1 (continued)

CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of those displays associated with the channels required by the LCO.

SR 3.3.3.1.2 and SR 3.3.3.1.3 A CHANNEL CALIBRATION is performed every 92 days for Functions 9 and 10 and every 24 months. for all other Functions. CHANNEL CALIBRATION is a complete check of the instrument loop including the sensor. The test verifies that the channel responds to the measured parameter with the necessary range and accuracy. For Function 5, the CHANNEL CALIBRATION shall consist of an electronic calibration of the channel, excluding the detector, for range decades

~ 10 R/hour and a one point calibration check of the detector with an installed or portable gamma source for the range decade < 10 Rlhour. For Function 8, the CHANNEL CALIBRATION shall consist of a position verification using the criteria specified in the Inservice Testing Program.

For Function 9, the CHANNEL CALIBRATION shall consist of a calibration at one volume percent and four volume percent hydrogen (balance nitrogen). The 92 day and 24 month Frequencies are Frequency is based on operating experience and engineering judgement.

1.

Regulatory Guide 1.97, "Instrumentation for Light-Water Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident," Revision 3, May 1983.

2.

USAR, Section 7.5.2.1.

3.

10 CFR 50.36(c)(2)(ii).

NMP2 B 3.3.3.1-12 Revision 0,

Primary Containment Hydrogen ReGombiners B 3.6.3.1 B 3.6 CONTAINMENT SYSTEMS B 3.6.3.1 Primary CORtainment HyEirogen Recombiners (DELETED)

BASES The primary containment hydrogen recombiners eliminate th potential breach of primary containment due to a hydrogen oxygen reaction and is part of combustible gas control required by 10 CFR 50.44, "Standards for Combustible as Control in Light-Water-Cooled Reactors" (Ref. 1), an GOC 41, "Containment Atmosphere Cleanup" (Ref

). The primary containment hydrogen recombiners are quired to reduce the hydrogen and oxygen concentratio in the primary containment following a loss of coolant acci nt (lOCA).

he primary containment hydrogen recom mers accomplish this b

ecombining hydrogen and oxygen t orm water vapor. The vap is cooled and returned to the s pression pool, thus elimin ing any discharge to the en. onment. The primary contain nt hydrogen recombin IS manually initiated, since flammabili limits would not be eached until several days after a Desig Basis Acciden DBA).

inde endent primary containment hydrogen are provided. Each consists of controls located in t ontrol room, a power supply, and a recomb iner locate in tH reactor building. Recombination is accomplished y heatin a hydrogen air mixture to

> 1150°F. Th resulting wat vapor and discharge gases are cooled prior: 0 discharge from e unit. Air flows through the unit a approximately 150 S

, with a blower providing the rnof e force. A single recombir is capable of main ining the hydrogen and oxyge concentration in primary co ainment to S 5.0 volume percent (v (Ref.3). Two r combiners are provided to meet the req irement for redundancy and independence. Each reco iner is powered from a separate emergency bus and is provid with separate power panel and control panel.

Operating Procedures direct that the hydrogen and 0 gen concentration in primary containment be monitored foil ing a DBA and that the primary containment hydrogen recom iners be manually activated prior to the primary containment atmosphere reaching a bulk hydrogen and oxygen concentrations of 4.0 vlo and 4.5 vlo, respectively.

(continued)

NMP2 B3.6.3.1-1 Revision OJ

The primary containment hydrogen recombiners satisfy Criterion 3 of Reference 5.

primary containment following a n between the zirconium fuel rod ctor coolant; Radiolytic decomposition of wate n the Reactor oolant System; or b.

a.

Primary Containment Hydrogen Recombiners B3.6.3.

B 3.6.3.1-2 The primary containment hydrogen recombiners provide the capability of controlling the bulk hydrogen and oxygen concentrations in primary containment to less than a concentration of 5.0 vlo following a DBA. This control would prevent a primary containment wide hydroge burn, thus ensuring that pressure and temperature itions assumed in the analysis are not exceeded. The Ii iting DBA relative to hydrogen and oxygen generation is a OCA.

c.

sion of metals and d mposition of organic rials in the primary cont. ment.

b.

ration of relief valves in e Air Systems.

Oxygen may accumulate in the primary con nment following a OCA as a result of:

The calculation confirms that when the mitigating stems are actuated in accordance with plant procedures, th hydrogen and oxygen concentrations in the primary containment remains s 5.0 vlo (Ref. 3).

aluate the potential for hydrogen ccurnulatlon in ary containment following a LOCA, e hydrogen neration as a function of time following e initiation of he accident is calculated. Assumptions rec mended by Reference 4 are used to maximize the amou f hydrogen calculated.

DELETE ENTIRE PAGE NMP2

Primary Containment Hydrogen Recombiners B3.6.3.1 and oxygen production rate and the total hydr nand oxy production after a LOCA would be less than that alcula (j for the DBA LOCA. Also, because of the Iimi d.

e in this MODE, the probability of an accident requirin primary containment hydrogen recombiner is low.

fore, the primary containment hydrogen recom. ers a not required in MODE 3.

Operation with at least one primary containment hy ogen recombiner subsystem ensures that the post LO hydrogen and oxygen concentrations can be prevented from ing their flammability limit.

MODES 1 and 2, the two primary con inment hydrogen re biners are required to control th ydrogen and oxygen con tions within primary contai ent below their limit of 5.0 following a LOCA, assu 9 a worst case single failure.

Two primary containment hydrogen recombiners must be OPERABLE. This ensures operation of at least one prima containment hydrogen recombiner in the event of a wors ase single active failure.

DELETE ENTIRE PAGE APPLICABILITY d 5, the pro bility and consequences of a LOCA the pressure a temperature limitations in these MO S. Therefore, the

'mary containment hydrogen recombi rs are not required in t se MODES.

ith one primary containment hydrogen re

.mbiner inoperable, the inoperable primary containment hydroge ecombiner must be restored to OPERABLE status within 30 da In this condition, the remain ing OPERABLE primary c inment recombiner is adequate to perform the hydrogen a oxyge n control function. However, the overall reliability is reduced because a single failure in the OPERABLE re mbiner could result in reduced hydrogen and oxygen control capability. The 30 day Completion Time is based on the I probability of the occurrence of a LOCA that would generate hydrogen and oxygen in amounts capable of exceeding the flammability limits, the amount of time available after the event for operator action to prevent hydrogen and oxygen ACTIONS NMP2 B 3.6.3.1-3 Revision 0

DELETE ENTIRE PAGE Primary Containment Hydrogen Recombiners B 3.6.3.1 A.1 (continued) accumulation exceeding this limit, and the low probability of failure of the OPERABLE primary containment hydroge recombiner.

With primary containment hydrogen recs mbiners inoperab the ability to perform the hydr en and oxygen control fun

'on via an alternate capabili must be verified by a inistrative means withi hour. The alternate hydr n and oxygen contr capability is provided by the Primary tainment Vent, rge, and Nitrogen System and one RHR d spray subs em, The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time allows areas ble perio f time to verify that a loss of hydrogen and en ntrol function does not exist.

In addition, the alternat d

gen and oxygen control system capability must b rifled once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter to ensure its ued availability. Both the initial verification and al u

uent verifications may be performed as an adrnl Istr heck by examining logs or other information to termine th availability of the alternate hydroge nd oxygen co 01 system. It does not mean to perform e Surveillances n ded to demonstrate OPERABILITY f the alternate hydrog and oxygen control system. If th bility to perform the hyd en and oxygen control fun

' n is maintained, continued 0 eratton is permitted lth two hydrogen recombiners i ble for up to 7 days.

even days is a reasonable time to a w two hydrog recombiners to be inoperable becaus the hydrogen and ygen control function is maintained and be use of the low robability of the occurrence of a LOCA that w Id g

erate hydrogen and oxygen in the amounts capa ceeding the flammability limits.

NMP2 B 3.6.3,1-4 Revision 'I, 9 (A109)

Primary Containment Hydrogen Recombiners B 3.6.3.1 If any Required Action and associated Completion Time c not be met, the plant must be brought to a MODE in which t LCO does not apply. To achieve this status, the plant must e

brought to at least MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The all ed Completion TIme of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is reasonable, base n

operating experience, to reach MODE 3 from full ower conditions in an orderly manner and without c lenging lant systems.

SURVEILLANCE REQUIREMENTS is SR requires performance of a resista e to ground test of each heater phase to ensure that there ar 0 detectable grounds in any heater phase. This is accompl ed by verifying that the resistance to ground for any he er phase is ~ 1.0E6 ohms, within 30 minutes following comp tion of a system functional test (SR 3.6.3.1.1) or heatup of th system to normal operating temperature.

Operating experience has shown that these components pass the Surveillance when performed at the 24 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

Operating exp ence has s wn that these components usually pass the Su iIIaneewhen p ormed at the 24 month Frequency.

herefore, the Fre ency was concluded to be acceptab from a reliability stan int.

Perform ce of a system functiona est for each primary containm t hydrogen recombine ensures that the recombiners are OPERA E and can attain d sustain the temperature necessary for drogen reco ination. In particular, this SR requires ver cation tha e minimum heater coil outlet gas temperature i reas to ~ 1150QF in 5:1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> and that it is maintained 50 QF for z 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to check the capability of the reca iner to properly function (and that significant heater me are not burned out).

DELETE ENTIRE PAGE NMP2 B 3.6.3.1-5 Revision 0

DELETE ENTIRE PAGE Primary Containment Hydrogen Recombiners B 3.6.3.1 1.

10 CFR 50.44.

2.

10 CFR 50, Appendix A, GOC 41.

3.

USAR, Section 6.2.5.

4.

Regulatory Guide 1.7, Revision 2, November 10 CFR 50.36(c)(2)(ii).

NMP2 83.6.3.1-6 Revision 0

Primary Containment Oxygen Concentration B 3.6.3.2 B 3.6 CONTAINMENT SYSTEMS B 3.6.3.2 Primary Containment Oxygen Concentration BASES BACKGROUND APPLICABLE SAFETY ANALYSES The primary containment is designed to withstand events that generate hydrogen either due to the zirconium metal water reaction in the core or due to radiolysis. The primary method to control hydrogen is to inert the primary containment. With the primary containment inert, that is, oxygen concentration < 4.0 volume percent (v/o), a combustible mixture cannot be present in the primary containment for any hydrogen concentration. +he capability te-ifleft.the primary containment and maffitain oxygen

< 4.0 "110works together with the Hydrogen Recombiner System

{bCQ-3.6.3.1, UPrimary Gontainment l-Iydrogen RecombinefS!!.}

and the RHR Drywell Spray System (bGO 3.6.1.6, "RHR-D'Y....ell Spray") to provide redundant and diverse methods to mitigate events that prodl&Ge hydrogen and oxygen. For example, An event that rapidly generates hydrogen from zirconium metal water reaction will result in excessive hydrogen in primary containment, but oxygen concentration will remain s 5.0 vlo and no combustion can occur. bong term generation of both hydrogen and-oxygen from radiolytic decomposition of water may eventually result in a combustible mixture in primary containment, except that the hydrogen recombiners remove hydrogen and oxygen gases faster than tRey Gan be produced from radiolysis and again no combustion can occur. This LeO ensures that oxygen concentration does not exceed 4.0 vlo during operation in the applicable conditions.

The Reference 1 calculations assume that the primary containment is inerted when a Design Basis Accident loss of coolant accident occurs. Thus, the hydrogen assumed to be released to the primary containment as a result of metal water reaction in the reactor core will not produce combustible gas mixtures in the primary containment.

Oxygen, 'I.'hIGh is subsequently generated by radiolytiG decomposition of Jater, is recombined by the hydrogen reGombiners (bGO 3-.6.3.1) moro rapidly that it s produced.

Primary containment oxygen concentration satisfies Criterion 2 of Reference 2.

(continued)

NMP2 B 3.6.3.2-1 Revision G,

BASES (continued)

LCO APPLICABIL1TY ACTIONS Primary Containment Oxygen Concentration B3.6.3.2 The primary containment oxygen concentration is maintained

< 4.0 vlo to ensure that an event that produces any amount of hydrogen and oxygen does not result in a combustible mixture inside primary containment.

The primary containment oxygen concentration must be within the specified limit when primary containment is inerted,

except as allowed by the relaxations during startup and shutdown addressed below. The primary containment must be inert in MODE 1, since this is the condition with the highest probability of an event that could produce hydrogen and oxygen.

Inerting the primary containment is an operational problem because it prevents containment access without an appropriate breathing apparatus. Therefore, the primary containment is inerted as late as possible in the plant startup and de-inerted as soon as possible in the plant shutdown. As long as reactor power is < 15% RTP, the potential for an event that generates significant hydrogen and oxygen is low and the primary containment need not be inert. Furthermore, the probability of an event that generates hydrogen occurring within the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of a startup, or within the last 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> before a Shutdown, is low enough that these "windows," when the primary containment is not inerted, are also justified. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> time period is a reasonable amount of time to allow plant personnel to perform inerting or de-inerting.

If oxygen concentration is '2:: 4.0 vlo at any time while operating in MODE 1, with the exception of the relaxations allowed during startup and shutdown, oxygen concentration must be restored to < 4.0 vlo within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time is allowed when oxygen concentration is

'2:: 4.0 vlo because of the availability of other hydrogen and oxygen mitigating systems (e.g., hydrogen recombiners) and tRe low probability and long duration of an event that would generate significant amounts of hydrogen and oxygen occurring during this period.

(continued)

NMP2 B 3.6.3.2~2 Revlsion-s.